2
tax for 1990 in the amount of $7,035. The issues for decision
are: (1) Whether petitioner is entitled to a Schedule C
deduction for business expenses in excess of the amounts allowed
by respondent; and (2) whether petitioner is entitled to a
deduction for travel expenses in excess of the amount allowed by
respondent.2
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. Petitioner resided in Chicago,
Illinois, at the time his petition was filed.
Petitioner is a psychiatrist specializing in forensic
psychiatry. Petitioner had acted as a court psychiatrist for the
county of Los Angeles, California, and thus had become well known
in Southern California. In 1988, petitioner began working as a
forensic psychiatrist for a group based in Santa Monica,
California. This work lasted approximately 14 months. In 1990,
petitioner was hired by the Department of Mental Health for the
county of Riverside, California, to perform psychiatric services
in the county jails. Petitioner's contract with the county of
Riverside, California, was not for a fixed period of time, but
his employment actually lasted for 11 months in 1990. Petitioner
2 In a stipulation of settled issue filed with the Court,
petitioner conceded that he is not entitled to a Schedule A
deduction for unreimbursed employee expenses in the amount of
$10,877 claimed on his return.
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